Vulnerable Customers Overview Policy

As an Appointed Representative (AR) of ACL, we are required to adhere to this document and adopt the policy statements it sets out, or to incorporate them into your own policy statements. To be used in conjunction with the ACL Vulnerable Customers Academy Module.

On September 25th, 2020, the FCA set out new best practice guidance for firms to do more to protect vulnerable consumers:

“Today’s guidance sets out what firms should do to ensure vulnerable consumers are being treated fairly. We know many more customers will be struggling with their finances as a result of the impact of coronavirus. Supporting vulnerable consumers is a key focus for the FCA, and the recent coronavirus crisis has only highlighted its importance” (Christopher Woolard, interim Chief Executive at the FCA).

FCA Definition

“A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm - particularly when a firm is not acting with appropriate levels of care” (FCA FG21/1 Updated February 2021).

Policy Guidelines: *

Ensuring consumers have an appropriate degree of protection is central to what the FCA does. This includes protecting vulnerable consumers.

“We want vulnerable consumers to experience outcomes as good as those for other consumers and receive consistently fair treatment. We have regard to the general principle that consumers should take responsibility for their choices and decisions.

However, there are very real factors that might limit their ability to do so, and characteristics of vulnerability may result in consumers having additional or different needs and may limit their ability or willingness to make decisions and choices or to represent their own interests.”

These consumers may be at greater risk of harm particularly if things go wrong.

The FCA expect firms to provide their customers with a level of care that is appropriate given the characteristics of the customers themselves.

ACL’s Vulnerable Customers policy is based on this paper and is designed to deliver both the purpose and spirit of this guidance.